LeadWise B.V. is committed to protecting your personal data. This Privacy Policy explains what data we collect, why we collect it, how we use it, and what rights you have under the GDPR and other applicable law.
1. Who We Are
LeadWise B.V. is a private limited company incorporated under Dutch law (KVK: 91872324), with its principal place of business in Zeist, The Netherlands. We operate the website at www.leadwise.app and the LeadWise mobile app, a leadership subscription for new and first-time managers featuring weekly audio coaching, a self-assessment and 360° feedback, a personalised roadmap, and the Lisa AI management coach.
For the purposes of the GDPR, LeadWise B.V. is the data controller responsible for your personal data.
Contact: info@leadwise.app
2. Data We Collect
Data you provide directly
- Account data: name, email address and password when you register.
- Subscription and billing data: name, email and payment information when you subscribe to LeadWise. Payment is processed by the Apple App Store or Google Play, and we do not store full card numbers ourselves.
- Self-assessment data: your answers to the 60-statement manager self-assessment, which you complete when you join and again at set intervals during your subscription (including a further self-assessment at your one-year anniversary).
- 360° feedback data: if you invite your manager or team members to give you 360° feedback, we send them an invitation email. We do not store the reviewer's name or email address, and we do not link their responses back to their identity. We only store the feedback responses themselves, which cannot be attributed to any individual reviewer.
- AI coach interactions: the questions and messages you send to Lisa, our AI management coach.
- Waitlist data: if you join our waitlist ahead of launch, we collect your name and email address so we can notify you when LeadWise becomes available.
- Contact and enquiry data: information you send via our contact forms or by email.
Data collected automatically when you use the app
- Usage data: pages visited, time spent, features used, and your progress through the app, including completed content, exercises and badges.
- Push notification data: a device token used to send you weekly reminders and nudges. You can disable these at any time in your device settings.
- Device and browser data: IP address, browser type, operating system, device type.
- Cookies: the LeadWise website does not use cookies — see Section 10.
3. How We Use Your Data
- To create and manage your account and provide access to your LeadWise subscription.
- To process your subscription payment and manage billing.
- To generate and deliver your personalised self-assessment report by email.
- To facilitate 360° feedback by sending invitation emails on your behalf, and to compile the anonymised responses into your feedback report.
- To operate the Lisa AI management coach and provide coaching responses.
- To send weekly nudges and reminders to help you stay consistent.
- To send transactional emails such as subscription confirmations and report delivery.
- To respond to your enquiries and support requests.
- To comply with our legal obligations.
We do not use your data for targeted advertising. We do not sell your personal data to third parties.
4. Legal Basis for Processing
- Contract performance — to deliver the products and services you have purchased.
- Legitimate interests — to improve our products, prevent fraud, and communicate with you about your account.
- Legal obligation — where required by applicable law (e.g. tax and accounting obligations).
- Consent — where we explicitly ask for your consent, such as for optional marketing emails. You may withdraw consent at any time.
5. Sharing Your Data
- Google: we use Google as our infrastructure provider for both the Lisa AI management coach and our underlying data storage (Google Cloud Firestore). Your account data, progress data and AI coach conversations are stored and processed using Google's infrastructure, and we also use Google's infrastructure to process waitlist and contact form submissions. Coaching conversations are not used to train Google's external models.
- Cloudflare: our website is hosted and traffic is terminated through Cloudflare's network. Cloudflare acts as a data processor for website traffic under our instruction. We also use Cloudflare Turnstile, a privacy-focused tool that verifies form submissions are from real visitors rather than bots, without traditional CAPTCHA puzzles. Turnstile processes limited technical signals (such as IP address and browser information); Cloudflare acts as our processor for this purpose, and separately as an independent controller for signals it uses to improve Turnstile's own bot-detection capabilities. Further detail is in Cloudflare's Turnstile Privacy Addendum.
- Apple and Google (payment processing): subscription payments are processed through the Apple App Store or Google Play, depending on how you subscribed. These platforms process your payment details under their own privacy policies.
- Legal requirements: we may disclose your data where required by law or court order.
- Business transfers: in a merger or acquisition, your data may be transferred. We will notify you before it becomes subject to a different privacy policy.
6. Organisational Customers and Employers
If you use LeadWise through an organisation — for example, because your employer has purchased a group plan — the following applies in addition to the rest of this notice:
- Your individual results stay private. Your self-assessment scores, 360° feedback results, progress, completed exercises, badges and conversations with Lisa are never shared with or made visible to your employer, your manager, or anyone else in your organisation.
- Only aggregated, anonymised insights may be shared with the organisation. Where we provide any reporting to an organisational customer, it is aggregated across multiple users and anonymised so that it cannot be attributed back to any individual.
- Your organisation may have visibility of account-level data necessary for administering the subscription, such as whether a seat has been activated, but not the content of your activity within the app.
If your organisation's agreement with us ever required a different arrangement, we would tell you directly before any change took effect.
7. International Transfers
Google, our provider for AI processing and data storage, may process personal data in data centres located outside the EEA. Cloudflare, our website hosting and traffic provider, may also process data outside the EEA. Where this happens, we rely on appropriate safeguards, such as Standard Contractual Clauses approved by the European Commission.
You may request a copy of the relevant safeguards by contacting us at info@leadwise.app.
8. Data Retention
- Account data: retained for the duration of your subscription and up to 3 years after closure.
- Subscription and financial records: retained for 7 years to comply with Dutch tax law.
- Self-assessment responses: retained for the duration of your subscription plus 2 years, so you can track your progress over time.
- 360° feedback responses: since these cannot be attributed to an individual reviewer, they are retained for the duration of your subscription plus 2 years, in the same way as your self-assessment responses.
- AI coach interactions: retained for up to 12 months after your subscription ends, then anonymised or deleted.
- Marketing consent records: retained for as long as you remain subscribed and for 3 years after you unsubscribe.
- Waitlist data: retained until you ask us to delete it, or until 12 months after launch, whichever is sooner.
9. Your Rights
Under the GDPR you have the right to access, rectify, erase, restrict, port and object to the processing of your personal data. You also have rights related to automated decision-making.
To exercise any of these rights, email us at info@leadwise.app. We will respond within 30 days. We may need to verify your identity before processing your request.
10. Cookies and Tracking
This site does not use cookies, does not run analytics, and does not track visitors. The only browser storage in use is a single, temporary flag that remembers whether you've closed the exit pop-up during your current visit — it never leaves your browser, isn't linked to you in any way, and is cleared when you close your browser tab.
11. Children's Privacy
Our products are intended for adults in professional roles. We do not knowingly collect personal data from anyone under the age of 16. If you believe we have inadvertently collected data from a minor, please contact us at info@leadwise.app and we will delete it promptly.
12. Complaints
If you have a concern about how we handle your personal data, please contact us first at info@leadwise.app and we will do our best to resolve it.
You also have the right to lodge a complaint with the Dutch Data Protection Authority: Autoriteit Persoonsgegevens — www.autoriteitpersoonsgegevens.nl
13. Do-Not-Track
Some browsers include a Do-Not-Track (DNT) setting. No uniform technology standard for recognising DNT signals has been finalised and we do not currently respond to DNT signals. If a binding standard is adopted we will update this policy accordingly.
14. US Residents
If you are a resident of California, Colorado, Connecticut, Utah or Virginia you may have additional rights under applicable state privacy laws, including the right to know what data is collected, the right to deletion and the right to opt out of the sale of personal data.
We do not sell your personal data. To exercise any applicable rights, email us at info@leadwise.app.
15. Other Regions
Australia and New Zealand
We process personal data in compliance with Australia's Privacy Act 1988 and New Zealand's Privacy Act 2020. Complaints may be submitted to the relevant national privacy commissioner.
Canada
We process personal data in accordance with applicable Canadian privacy legislation including PIPEDA.
Republic of South Africa
You have the right to request access to or correction of your personal data at any time. Complaints may be submitted to the Information Regulator of South Africa.
16. Updates to This Notice
We may update this privacy notice from time to time. The updated version will be posted on this page with a revised date at the top. If we make material changes we will notify active users by email or platform notification.
If you have questions, concerns or requests relating to this privacy notice or your personal data, please contact us:
To review, update or delete your personal data, email us at info@leadwise.app.